Claims related to Class I, II, III, and IV medical devices as defined in the Medical Device Regulations (MDR) do not fall under the current scope of the PAAB. However, messages relating to drugs fall under the scope. The answer to your question therefore depends on whether the APS messaging relates to an entity which is classified as a drug or as a medical device. I note that your question relates specifically to DTC. Contrary to your question, PAAB assessments for consumer materials are based on the Health Canada guidance documents (not the PAAB code as suggested by "PAAB advertising rules").